Privacy Policy

INTRODUCTION

This Company Policy Manual establishes the guiding principles, rules, and standards
governing all operations of Romat Group and its subsidiaries. It ensures consistency,
professionalism, compliance with Nigerian laws, and alignment with the Group’s vision of
building a leading multi-sector conglomerate.
This policy applies to:

• All employees
• Management and executives
• Directors
• Contract staff and consultants

2. CORPORATE GOVERNANCE POLICY
2.1 Governance Structure
Romat Group operates under a structured governance system consisting of:

• Board of Directors
• Group CEO
• Subsidiary
• Management Teams

2.2 Decision-Making

• Strategic decisions are made at the Board level for the Group /Subsidiary Management
  level for the subsidiaries
• Operational decisions are handled by subsidiary management.
• All major investments require Board approval.

2.3 Ethical Leadership
All leaders must:

• Act in the best interest of the company
•  Avoid conflicts of interest
• Maintain transparency and accountability

3. CODE OF CONDUCT
3.1 Professional Behavior
Employees must:

• Conduct themselves with integrity and respect
• Maintain professionalism in all dealings
• Avoid misconduct, harassment, or discrimination
• Avoid doing personal things while on duty that do not concern the company
• Avoid abusive words, throwing tantrums
• Have zero tolerance for laziness or delay in job delivery.

3.2 Conflict of Interest
Employees must:

• Disclose any personal or financial interest that conflicts with company business
• Avoid using the company position for personal gain

3.3 Confidentiality

• Company information must not be disclosed without authorisation
• Applies during and after employment

4. HUMAN RESOURCE POLICY
4.1 Recruitment

• Based on merit, competence, and company needs
• Equal opportunity employer (no discrimination)

4.2 Employment Categories

• Full-time staff
• Contract staff
• Interns

4.3 Working Hours

• Standard: 8 hours daily (Monday–Friday)
• Breaktime 1:30 pm – 2:00 pm (Monday – Friday)
• Adjustments may apply based on business needs

4.4 Leave Policy

• Annual Leave: Minimum 15 working days
• Sick Leave: As approved with medical report
• Maternity Leave: In line with Nigerian Labour Law
• Casual Leave: Subject to management approval

4.5 Performance Management
Employees are evaluated based on:

•  Productivity
• Initiative
• Team contribution
• Achievement of targets

5. FINANCIAL POLICY
5.1 Financial Discipline

• All expenses must be approved and documented
• No unauthorised spending

5.2 Revenue Handling

• All income must be properly recorded
• Use official company accounts only

5.3 Audits

• Internal audits are conducted periodically
•  External audits annually

6. PROCUREMENT POLICY
6.1 Vendor Selection

• Based on quality, cost, and reliability
• Competitive bidding encouraged

6.2 Approval Process

• All purchases must be approved before execution
• Large procurements require management approval

7. OPERATIONS POLICY
7.1 Efficiency & Quality

• All subsidiaries must maintain high operational standards
• Deliver quality products/services consistently

7.2 Health & Safety

• Maintain safe working environments
• Comply with safety regulations
• Provide protective equipment where necessary

8. INFORMATION TECHNOLOGY POLICY
8.1 Acceptable Use

• Company systems, gadgets, router, etc. must be used for official purposes
• Unauthorised software installation is prohibited

8.2 Data Protection

• Secure storage of company data
• Compliance with Nigeria Data Protection laws

9. MARKETING & BRANDING POLICY
9.1 Brand Consistency

• All subsidiaries must use approved Romat branding
• No unauthorised logos or designs

9.2 Public Communication

• Only authorised personnel may speak on behalf of the company to the press
• Maintain professional corporate image

10. COMPLIANCE & LEGAL POLICY
10.1 Regulatory Compliance
Romat Group complies with:

• Nigerian Labour Laws
• Corporate Affairs Commission (CAC) regulations
• Tax laws and statutory obligations

10.2 Legal Representation

• All legal matters handled by appointed legal advisers
• No employee may commit the company legally without authorisation

11. DISCIPLINARY POLICY
11.1 Misconduct
Includes:

• Theft or fraud
• Absenteeism
• Insubordination
• Breach of company policies

11.2 Disciplinary Actions

• Verbal warning
• Written warning
• Suspension
• Termination

12. ANTI-CORRUPTION POLICY

• Zero tolerance for bribery or corruption
• Employees must not offer or accept bribes
• Violations lead to immediate disciplinary action

13. ENVIRONMENTAL POLICY

• Promote environmentally sustainable practices
• Reduce waste and pollution
• Encourage responsible resource use

14. SUBSIDIARY ALIGNMENT POLICY
All subsidiaries must:

• Align with Romat Group strategy
• Submit periodic performance reports
• Follow Group-wide policies

15. REVIEW & AMENDMENT

• This policy shall be reviewed annually
• Amendments require Board approval

16. CONCLUSION
This policy framework is designed to guide Romat Group toward:

• Operational excellence
• Strong governance
• Sustainable growth
• Becoming a leading conglomerate